Argentina’s ambitious move to launch its first Citizenship by Investment (CBI) program has hit a significant procedural roadblock. The Ministry of Economy, led by Minister Luis Caputo, has officially cancelled the international tender to appoint a master agent who would have overseen the program’s design, launch, and promotion.
The decision, formalized through Resolution 522/2026 on April 14, 2026, marks a “reset to zero” for the operational side of a program that has been closely watched by the global investment migration industry.
What Triggered the Cancellation?
The tender process (34-0001-CPU25) initially appeared to be nearing completion. In March 2026, an evaluation commission recommended awarding the four-year contract to a consortium known as Asesorías Legal Advisor Limitada.
However, the recommendation sparked immediate legal resistance. Two competing firms filed formal challenges (impugnaciones) within the permitted three-day window:
- Henley & Partners: Who had ranked second in the technical and economic evaluation.
- Latitude Consultancy: Who had been declared inadmissible at an earlier stage due to financial solvency indices.
Following these challenges, the Ministry’s legal and administrative department conducted a technical review. The report concluded that despite having admissible offers, “relevant divergences” persisted regarding how the program should align with public policy objectives.
“Continuing under the current conditions could not ensure the degree of coherence and strategic articulation required,” the Ministry stated, advising a full re-evaluation of the process.
The Evaluation Gap: From $50,000 to $25 Million
The tender revealed a stark contrast in bidding strategies. While both the winning consortium and Henley & Partners received identical technical scores (48 points), their economic proposals were worlds apart:
- The Consortium: Bid a total of $50,000 for the entire contract.
- Henley & Partners: Bid a total of $25 million, with tranches escalating based on application volume.
This massive disparity, combined with the procedural challenges from disqualified bidders, likely contributed to the Ministry’s decision to void the tender entirely without awarding compensation to any party.
What Remains of the Argentina CBI Program?
While the procurement of a master agent has ended, the legal foundation for Argentina’s CBI program remains intact. The following legislative frameworks are still in force:
- Decree 366/25: Permits naturalization through relevant investment regardless of residency duration.
- Decree 524/25: Established the Investment Citizenship Program Agency (APCI).
- Tax Decoupling: The amendment ensuring that CBI citizens are not automatically considered tax residents still stands.
What’s Next for Investors and Agents?
For now, the operational substance of the program, including qualifying investment thresholds, eligible sectors, and processing routes remains non-existent. These were the very elements the master agent was supposed to develop.
The Ministry of Economy has yet to indicate whether it will:
- Issue a new, restructured tender.
- Build operational capacity directly within the government agency (APCI).
For the investment migration community, Argentina remains a high-interest jurisdiction, but one that is currently “on hold” as the government navigates administrative and economic pressures, including ongoing discussions with the IMF and domestic inflation concerns.
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